Subject: File No. S7-08-08
From: GARY J MANFRE
Affiliation: ACCOUNTANT

May 14, 2008

Stock loan sales representaves borrow the shares to cover delivery of short sales.

They are NOT required to have their Series 7 63 licenses.

They should be required to get their series 7 and 63 licenses and there should be a special additional test to be a security lending sales person.

Thank you.